Web Content DisplayWeb Content Display

FAQ - Frequently Asked Questions

Here you can find questions and answers regarding IMDS content and usage in several categories. To see the content of each category and to read the answer to a question, please click on the category/question to expand the content.

You find OEM-specific IMDS documentation for suppliers in the Help category "OEM Specific Information" (no longer under FAQ).

Where can I find out more about the new Conflict Minerals Group?

Why is there now a Conflict Minerals group? On July 15, 2010 the US Congress passed the Wall Street reform bill that included a provision on conflict minerals. The language in the bill requires companies that use tin, tungsten, tantalum, or gold in their products or production of their product and report to the US Securities and Exchange Commission to file an annual disclosure report with the Securities and Exchange Commission detailing whether these materials originated in the Congo or its adjoining countries. The bill requires companies to audit these reports to assure whether they are sourcing from conflict mines or not.

Several OEMs are cascading an information letter through the supply chain making suppliers aware of this new requirement. In the letter they ask suppliers to:

Determine what components use conflict minerals or their derivatives.

Work with suppliers to map supply chains of those components.

Require suppliers to identify smelters used or verify that the origin of conflict minerals is scrap or recycled material.

In order to facilitate the first step, we have introduced the Conflict Minerals group that can be used for analysis.

(A) columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives; or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of the Congo or an adjoining country.

In other words, it is not just where the mineral comes from that makes it a conflict mineral.

Are the substances in the Conflict Minerals group a complete list of substances I need to be concerned about? No. The substances in this IMDS group are substances that are found in the IMDS Basic Substance list. These substances are commonly found in hard parts. There are many other compounds that are used in manufacturing (necessary to the production of the part) that are not found in final parts.

How can I use the Conflict Minerals group? To examine the structure of an individual MDS, you may use the pull down and conflict minerals will be highlighted in the tree similar to GADSL substances or Process Chemicals. You may also use this group in Analysis > Certificate of Expenditure > Basic Substance List to determine which parts contain Conflict Minerals so you can determine which suppliers you may need further information from.

For the legislation, do I only need to look at my parts and materials in IMDS? No. The legislation (New Section 13(p)) requires reporting annually whether Conflict Minerals that are necessary to the functionality or production of a product originated in the Democratic Republic of the Congo (DRC) or an adjoining country (such countries are referred to in this memorandum as the DRC Countries).

While the final guidelines from the SEC are not published at this time, we are expecting that this means all tooling, catalysts, etc., are also included in the reporting requirement. Only parts on a vehicle as sold are reported in IMDS.

After I find my parts and suppliers, what do I have to do next? That is really up to you and your customer requirements. Some of your customers may require a formal report asking for information on the source of the Conflict Minerals. Communications with your suppliers on this topic will need to be done outside of IMDS. IMDS is only a starting point on this journey.

If your company reports to the US SEC, you may be asked to contribute to such a report.

What do I do if I use IMDS Committee materials with these substances in them? As it says in Recommendation 001, that even if you use IMDS Committee materials, you are required to collect information to ensure that the IMDS Committee material is representative of the material being used. You will need to use that information to contact your suppliers for information if it is required.

The Automotive Industry Action Group has a working group on Conflict Minerals (www.aiag.org).

You may use a search engine such as Google to search on the term: Conflict Minerals.

Is there a recommendation how to handle DBT and DOT in IMDS? (outdated, new version under development)

The IMDS Steering Committee summarizes how to handle organic tin compounds in this document.

How does IMDS support the Biocidal Product Regulation?

Declaration of Biocides in IMDS

Introduction:

In August 2014 GADSL contains for the first time biocidal active substances according to EC 528/2012 "Biocidal Product Regulation" (Regulation (EU) No 528/2012 of the European Parliament and of the Council of 22 May 2012 concerning the making available on the market and use of biocidal products).

As the regulations concerning biocides are extremely complex, it is recommended that you do NOT reject data sheets without following the guidance in this FAQ.

Following the former Biocidal Product Directive (DIRECTIVE 98/8/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 16 February 1998 concerning the placing of biocidal products on the market) active substances are assigned to 22 so called product-types. The producer had to notify the substance and the use.

In a first step it was agreed to focus on the following product-types as automotive parts relevant:

More strictly than in the former regulation, the legislator now restricts the use of biocides. In a review program the known biocides are evaluated again and are either listed as included, under approval or are delisted. To fulfill regulatory duties within the EU as producer or importer, only active substances that are approved for the relevant product-type, or are in the approval process for the relevant product-type, may be used. The use of delisted substances is not allowed at all. In each case the assigned product-type has to be taken into account.

Listing in GADSL:

The selected active substances are listed under "Biocidal coatings / biocidal additives, selected". In the column "Source" the assigned allowed (D) or restricted (P) product-types are shown. Several substances are not legally classified as allowed or prohibited for all product-types. As a use as biocide is only allowed when authorized for the respective use, they have the GADSL entry "Authorisation as biocide needed for product-type". E.g.:

Substance

CAS-No.

Classification

Reason Code

Source (Legal requirements, regulations)

Biocidal coatings / biocidal additives, selected

D/P

LR

Reg. (EU) No 528/2012 This list is derived from the following product-types believed to be relevant to the GADSL criteria: product-type 7: Film preservatives; product-type 8: Wood preservatives and product-type 9: Fibre, leather, rubber and polymerised materials preservatives. These requirements apply only to intended use as a biocide.

Cis-4-[3-(p-tert-butylphenyl)-2-methylpropyl]-2,6-dimethylmorpholine

67564-91-4

D/P

LR

P: Forbidden use as biocide in product-type : 7 D: Allowed use as biocide in product-type : 8 P: Forbidden use as biocide in product-type : 9

L-(+)-lactic acid

79-33-4

D/P

LR

Authorisation as biocide needed for product-type 7 P: Forbidden use as biocide in product-type : 8 Authorisation as biocide needed for product-type 9

Use in IMDS:

Biocides with the GADSL classification D will be identified in blue. Biocide substances with the GADSL classification P or D/P will be identified in red, as they are not permitted in certain "Product-Types".

Just because a biocidal substance is reported in your material, does not mean that it is subject to the Biocidal Product Regulations – if this substance is added for non-biocidal reasons (e.g. if it is a vulcanizing agent, heat stabilizer, catalyst etc) then the provisions of the BPR do NOT apply and the data sheet should NOT BE REJECTED.

Please follow the recommended steps in the IMDS process:

1. Gather data on these active substances in IMDS.

2. For substances identified as red, you will need to review the IMDS data against the Biocidal additives listing in GADSL (see www.GADSL.org).

3. The following guidelines will help to determine if a use is acceptable.

3a. If the IMDS Material Category is not 6.1 or 9.7, then this material is UNLIKELY to be product-type 7. Closer inspection of the datasheet should reveal if this is a film, or a larger polymer substrate. If only product-type 7 is prohibited, and your material is clearly NOT a film, you can be confident that your material is OK.

3b. If the IMDS Material Category is not 7.1 or 9.7, then this material is NOT product-type 8, therefore if only product-type 8 is prohibited, you can be confident that your material is OK.

3c. If the IMDS Material Category is 5.x, 6.1, 9.7, then there is a good chance that this material IS product-type 9, therefore if product-type 9 is prohibited, there is a strong possibility that your material is NOT OK.

3d. If the material category is 7.1 - it is most likely a wood product or a leather product. Please look in more detail at the name to see if it is a wood (PT 8 restrictions will apply) or leather (PT 9 restrictions will apply).

In the near future, IMDS will be modified to provide additional functionality to determine if the biocidal substance has in fact been added for its biocidal properties and to identify which product-type it is used in. It will be the responsibility of the Material MDS creator to provide this information.

If it is reported in IMDS as an elastomer (with material category 5.2) then it has NOT been added as a wood preservative and its use in IMDS is ACCEPTABLE.

2. I add a biocide to my ECOAT bath to prevent algal growth. Do I need to declare this in IMDS?

No – The biocide added to the ecoat is not designed to impart any biocidal property on to the painted article itself, therefore it does not need to be declared in IMDS. However, the biocide does need to be approved for Product-Type 7 (or in the process of being approved) and you need to be working within the approval conditions in your manufacturing facility.

What are the latest recommendations of the automotive industry in regard to REACH?

Please consult www.acea.be/reach, there you can find "REACH: Automotive Industry Guideline" as well as other useful sources and links.

Is it mandatory to register a REACH contact for every company?

The registration of a REACH contact is not mandatory for the IMDS system. It was implemented to facilitate the communication between companies. Even if no REACH contact is registered for your own company, the users can send and receive MDSs. However, please ask your customer or supplier whether it is necessary to register at least one REACH contact.

Is there a common interpretation of the exemptions listed in the ELV Directive?

REACH Article 33 is requiring manufacturers of articles to automatically inform their customers on substances listed on the candidate list if this substance is contained in the article in an amount > 0.1% w/w. Ignoring this legal obligation may cause penalties by the national authorities.

To fulfil these legal obligations, suppliers can use the IMDS system but have to follow the IMDS-Recommendations, especially of IMDS Rec. 001:

It is prohibited to hide GADSL-substances in wildcards

After a GADSL-update, ALL active MDS have to be checked for ALL new GADSL-substances, potentially hidden in a wildcard.

If new GADSL substances are hidden in wildcards, the supplier has to re-work and re-submit the affected MDS to his customer immediately.

For Renault suppliers: In case of an update of the Renault list you have to follow the same rules.

To avoid such checks and re-submission in the future, the IMDS Steering Committee recommends to avoid the usage of any wildcard and instead, without losing your company knowledge, to use the “confidential substance”-functionality.

What are REACH-related changes of the IMDS?

Having the IMDS, the automotive Industry is considered to be in an advantageous position compared to other sectors and able to comply with several REACH obligations immediately e.g. Art. 33.1 communication without developing new tools or processes.

The Automotive Industry Guideline on REACH includes the recommendation that the IMDS should be used to collect information about substances of very high concern in articles. Minor modifications to the system have been implemented to optimise this process:

IMDS provides an additional REACH contact field, on company and not material data sheet level, to support better REACH communication throughout the supply chain. Please note that use of this function will not replace your obligation to provide the contact information by the direct customer-specific communication requirements.

It is important to remember that in order to ensure compliance to the REACH Regulation, material data sheets may need to be re-submitted for each active part number to include any candidate list substance that has been added to the GADSL. This specifically applies to substances that up till now were hidden by a wild card or considered confidential.